The Sequoia Project’s Public Health Workgroup has released a draft Public Health Interoperability Policy Roadmap. This 17-page white paper offers a 15-step framework for improving public health data sharing and interoperability, targeting public health agencies, healthcare providers, and Health Information Exchange (HIE) stakeholders.
The roadmap covers familiar territory in public health data modernization: policy analysis, governance frameworks, technology assessment, standards adoption, data sharing agreements, workforce training, and pilot projects. It aligns with national initiatives like TEFCA and emphasizes the need to modernize outdated policies that prevent effective data exchange.
HLN submitted comments informed by its involvement in standards development efforts and interoperability projects in immunization information systems (IIS), electronic case reporting (eCR), and health information exchange (HIE). The roadmap provides a reasonable general framework for improving interoperability and data governance. However, it does not give sufficient credit to the numerous, mature, and successful public health interoperability initiatives and capabilities that have already been developed and deployed. Many agencies have worked on the kinds of regulatory analyses, data sharing policies, and technology needs assessments prescribed in the roadmap, and are successfully exchanging data across a number of use cases today.
We see the roadmap as an opportunity to highlight successful use cases as examples for others to follow, and to make a call for sustained funding for Public Health to be able to operationalize and build on these successes.
Steps Towards Improving Interoperability
The early steps of the framework focus on understanding the current state: taking an inventory of existing regulations and policies that affect data sharing, conducting a technology needs assessment, and establishing an enterprise-wide governance framework. The document emphasizes that siloed, program-by-program governance won’t work. From there, the roadmap moves to standards adoption, mentioning FHIR, SNOMED CT, LOINC, and ICD-10.
FHIR and USCDI Should Be Strategic Priorities
While FHIR is listed as one option among many in Section 6.5, this framing is likely an artifact of the dominance of IHE-CDA based transactions in TEFCA (and Sequoia initiatives) today. It understates the dominance of FHIR in modernization efforts and in the federal strategic direction. HHS has made FHIR central to health IT interoperability policy. ASTP’s HTI-5 proposed rule refocuses the certification program on FHIR-based APIs, TEFCA now supports FHIR-based query, and CDC has established FHIR-based exchange as a priority for public health modernization. HLN recommends explicitly acknowledging FHIR as the strategic direction for public health interoperability and encouraging agencies to prioritize FHIR adoption in their modernization planning, consistent with HHS, ASTP, and CDC guidance.
The document discusses common data models, but does not mention the US Core Data for Interoperability (USCDI) or USCDI+, a standardized set of health data classes and elements for interoperability and quality measurement. HLN recommends USCDI and USCDI+ as foundational standards that public health agencies should align with, particularly given EHR certification requirements that drive what data is available for public health reporting.
CDC has funded ASTHO, NNPHI, and PHAB to establish Implementation Centers specifically to help state, territorial, local, and tribal public health departments adopt FHIR and USCDI. As of February 2026, the program is on hold, but nevertheless it is a potential resource for STLTs that could be mentioned.
The roadmap goes on to address modernizing legacy systems, implementing or enhancing HIEs, and integrating with existing public health platforms. Subsequent steps include data sharing agreements, workforce training, and piloting interoperability solutions.
Public Health Use Cases Are Foundational
For a public health interoperability roadmap, it is notable that there is no specific discussion of IIS, eCR, Electronic Laboratory Reporting (ELR), or syndromic surveillance use cases. These use cases are an opportunity to point to examples for others to follow as well as to make a case for sustained Public Health funding.
The HTI-1 Final Rule includes specific requirements for public health reporting (immunization information system reporting and electronic case reporting) which have compliance deadlines that create external pressure and opportunities for public health agencies. HLN recommends that the roadmap include discussion of HTI-1 requirements and how they create both obligations and opportunities for improved data flow to public health.
TEFCA is mentioned in the executive summary, but the roadmap does not provide guidance on how public health agencies should position themselves relative to Qualified Health Information Networks (QHINs), what use cases TEFCA enables for public health, or how TEFCA participation fits into a modernization strategy. HLN recommends that the TEFCA discussion be expanded to include guidance on public health agency participation options and use cases.
As noted in the roadmap, there are numerous opportunities for agencies to pursue interoperability testing and piloting, including the Helios FHIR Accelerator, HL7 FHIR Connectathons, HIMSS Interoperability Showcases, and CDC-sponsored events.
The framework concludes with steps on data quality, security, monitoring and evaluation, and stakeholder engagement.
Looking Ahead
The roadmap is a reasonable framework for improving interoperability and data governance, and presents a solid foundation for agencies beginning their interoperability journey. Most importantly, it should celebrate and build on existing successes. Many agencies are already exchanging data effectively across multiple use cases. The path forward is less about starting from scratch and more about sustaining and scaling what works.